Log in

Relevant bibliographies by topics / Double taxation Treaties

Contents

Journal articles
Dissertations / Theses
Books
Book chapters
Conference papers
Reports

Academic literature on the topic 'Double taxation Treaties'

Author: Grafiati

Published: 4 June 2021

Last updated: 31 July 2024

Create a spot-on reference in APA, MLA, Chicago, Harvard, and other styles

Select a source type:

Consult the lists of relevant articles, books, theses, conference reports, and other scholarly sources on the topic 'Double taxation Treaties.'

Next to every source in the list of references, there is an 'Add to bibliography' button. Press on it, and we will generate automatically the bibliographic reference to the chosen work in the citation style you need: APA, MLA, Harvard, Chicago, Vancouver, etc.

You can also download the full text of the academic publication as pdf and read online its abstract whenever available in the metadata.

Journal articles on the topic "Double taxation Treaties"

1

Arzu Jabbarov, Rahman. "INTERNATIONAL DOUBLE TAXATION: DSOUBLE TAXATION AGREEMENTS (DTA)." SCIENTIFIC WORK 65, no. 04 (April 23, 2021): 328–32. http://dx.doi.org/10.36719/2663-4619/65/328-332.

Full text

Abstract:

As a result, present taxation, avoidance of double taxation and Double Taxation Agreements (DTA) are important elements of international trade relations. All states are interested in harmonizing tax systems to expand trade and other ties with each other. Thus, importance of double taxation agreements (DTA), structure of these treaties nneds to be resarched and stuidied in that article. Key words: taxation, history of double taxation, avoidance of double taxation, double taxation agreements, mechanics of double tax avoidance

APA, Harvard, Vancouver, ISO, and other styles

2

Eyitayo-Oyesode, Oladiwura Ayeyemi. "Source-Based Taxing Rights from the OECD to the UN Model Conventions: Unavailing Efforts and an Argument for Reform." Law and Development Review 13, no. 1 (February 25, 2020): 193–227. http://dx.doi.org/10.1515/ldr-2018-0073.

Full text

Abstract:

AbstractA significant number of scholars have written about the nexus between fairness in the allocation of taxing rights in double taxation treaties and sustainable development in developing countries. These scholars have argued for expansive taxing rights for developing countries, as against the current source- restricting provisions in taxation treaties between developed and developing countries based on the OECD and UN Model taxation treaties. They have also highlighted the need for developing countries to critically assess their treaty networks, and to consider gaps in their local laws and policies that encourage revenue loss. This paper contributes to this body of knowledge by identifying provisions in Nigeria’s double taxation treaties that encourage revenue loss. It concludes by recommending amendments to Nigeria’s double taxation treaties.

APA, Harvard, Vancouver, ISO, and other styles

3

Kuzniacki, Blazej. "The Need to Avoid Double Economic Taxation Triggered by CFC Rules under Tax Treaties, and the Way to Achieve It." Intertax 43, Issue 12 (December 1, 2015): 758–72. http://dx.doi.org/10.54648/taxi2015070.

Full text

Abstract:

The present article deals with the problem of double economic taxation triggered by CFC rules under tax treaties based the Model Tax Convention of the Organisation for Economic Co-operation and Development (OECD tax treaties). In that respect, the author first provides and analyses several arguments speaking in favour of the thesis that OECD tax treaties target double economic taxation triggered by an application of the CFC rules and the treaties therefore require Contracting States applying CFC rules to avoid said double economic taxation. Subsequently, the way in which the double economic taxation should be avoided by Contracting States is discussed. Finally, the author concludes that the need to avoid double economic taxation triggered by the application of CFC rules under OECD tax treaties is internationally recognized and respected and that the appropriate way to achieve it is to credit taxes paid by the CFC if this company does not constitute a PE of its participants, or, exempt its income from taxation if it constitutes a PE of its participants and the exemption method applies to its income.

APA, Harvard, Vancouver, ISO, and other styles

4

Du Plessis, Izelle. "Double Taxation Treaty Interpretation: Lessons from a Case Down Under." Potchefstroom Electronic Law Journal 23 (December 8, 2020): 1–22. http://dx.doi.org/10.17159/1727-3781/2020/v23i0a6840.

Full text

Abstract:

In the Australian case of Bywater Investments Ltd v Commissioner of Taxation; Hua Wang Bank Berhad v Commissioner of Taxation (the Bywater case) the Australian High Court dealt with the question of whether certain companies were resident in Australia for income tax purposes. The majority answered this question by applying Australian domestic law. In a separate but concurring judgement, Gordon J also discussed the interpretation and application of the relevant double taxation treaty. This contribution analyses Gordon J's judgment to extract guidance from it for the South African courts on their interpretation of double taxation treaties. It is submitted that South African courts should also follow the "first step" proposed by Gordon J when interpreting double taxation treaties. South African courts may find Gordon J's judgment "instructive" when dealing with the interpretation of the "place of effective management" concept in both domestic law and double taxation treaties. In his judgment Gordon J favours the goal of common interpretation and it is argued that South African courts should follow this example and explicitly support this notion in applicable cases. From Gordon J's judgment and the judgement in Krok v Commissioner, South African Revenue Service, it is deduced that the positions in South Africa and Australia are similar in that the courts in both countries will be bound by the principles of Articles 31 and 32 of the Vienna Convention on the Law of Treaties when interpreting double taxation treaties. Moreover, Gordon J's judgment indicates that the domestic principles of interpretation should not be used in the interpretation of double taxation treaties. Recent South African cases have suggested that there are no differences between the South African domestic principles of interpretation and those contained in Articles 31 and 32 of the Vienna Convention on the Law of Treaties. This contribution submits that there are many similarities between the two, but that the rules are not exactly the same. South African courts should be aware of these differences and rather apply the rules of public international law, including those contained in the Vienna Convention on the Law of Treaties, when they interpret double taxation treaties. Gordon J specifically identifies the category of the Vienna Convention on the Law of Treaties in which he places the Commentary on the OECD Model Tax Convention, to rely on it for his interpretation of the relevant double taxation treaty. South African courts may well learn from this approach, to create more certainty in the process of interpreting a double taxation treaty.

APA, Harvard, Vancouver, ISO, and other styles

5

Saccardo, Nicola. "Inheritance, estate and gift tax treaties—Italy." Trusts & Trustees 26, no. 1 (November 26, 2019): 41–48. http://dx.doi.org/10.1093/tandt/ttz111.

Full text

Abstract:

Abstract Italy is party to seven inheritance/estate tax treaties, concluded with Denmark, France, Greece, Israel, Sweden, the USA and the UK. The treaty with France also covers gift tax. The article describes the ramifications of such treaties in terms of the elimination of double taxation, by either restricting Italian taxation as the State of situs of the assets or dealing with dual residence cases. The article also highlights both the interpretation issues raised by these (old) treaties and the limits of such treaties in eliminating double taxation.

APA, Harvard, Vancouver, ISO, and other styles

6

Stratilatova, A., R. Ahmadeev, E. Golubcova, and A. Agapova. "Double Tax Treaties: Fiscal Security of the State." Scientific Research and Development. Economics 9, no. 2 (April 22, 2021): 65–70. http://dx.doi.org/10.12737/2587-9111-2021-9-2-65-70.

Full text

Abstract:

In today's economy, the basis for optimal tax policy is a holistic approach in the application of international agreements to avoid double taxation. Contracts applicable between jurisdictions are the main instruments for resolving tax disputes and conflicts by taxpayers. The validated double taxation process in each country depends to a large extent on the structure of the tax base, the status of the taxpayer and the established rules for determining taxable income. The object of the study is social relations arising in the field of legal regulation of double taxation. In turn, the subject of study is legal norms, international treaties and agreements regulating social relations arising in the sphere of legal regulation of double taxation. In the practice of international taxation, more than 3000 bilateral international treaties on avoidance of double taxation of personal income and prevention of tax evasion are applied, whereas in Russia, this figure exceeds 80 existing agreements. Under the current legal system, the provisions of double taxation agreements have priority over the provisions of the domestic tax legislation. The analysis of changes in bilateral international double taxation treaties between Russia and Cyprus, Luxembourg and Malta in 2020 allowed identifying important aspects of their legal application and formulating the main tasks necessary for the development of tax potential and successful cooperation in the field of regulation of trade and economic relations.

APA, Harvard, Vancouver, ISO, and other styles

7

Zhelekhovska, Tetiana. "Legal mechanism of avoiding double taxation in the European Union." Visegrad Journal on Human Rights, no. 4 (December 26, 2023): 103–10. http://dx.doi.org/10.61345/1339-7915.2023.4.18.

Full text

Abstract:

The article titled “Legal Mechanism of Avoiding Double Taxation in the European Union” provides a comprehensive examination of the intricate legal framework established within the European Union (EU) to tackle the pervasive issue of double taxation. The contemporary landscape of the European Union is characterized by a dynamic and interconnected economic environment, fostering a thriving cross-border business ecosystem. However, this vitality often encounters significant impediments in the form of double taxation, where individuals or entities are subject to taxation in multiple EU member states for the same income or transaction. Double taxation not only creates administrative burdens but also undermines the seamless operation of the EU’s internal market. The article provides a comprehensive understanding of double taxation, delineating its various forms. It highlights the potential consequences of double taxation on businesses and individuals, such as reduced competitiveness, disincentives for foreign investment, and impediments to economic growth within the EU etc. Against this backdrop, the article delves into the central theme of the legal mechanisms implemented by the European Union to combat double taxation. It recognizes that while taxation is primarily within the purview of individual member states, the EU has intervened with a series of directives, treaties, and judicial rulings to harmonize and streamline tax practices. The article “Legal Mechanism of Avoiding Double Taxation in the European Union” explores the complex and crucial issue of double taxation within the EU. It delves into the various legal instruments, directives, and tax treaties that have been established to prevent or mitigate double taxation, which can arise when individuals or businesses are subject to taxation in multiple EU member states. The article provides insights into key EU directives, bilateral tax treaties, European Court of Justice practice etc.

APA, Harvard, Vancouver, ISO, and other styles

8

Bruk, Boris Ya. "Methodological Issues in the Use and Application of International Tax Treaties (Part 2)." Zakon 20, no. 12 (December 2023): 183–87. http://dx.doi.org/10.37239/0869-4400-2023-20-12-183-187.

Full text

Abstract:

In this article the author intends to develop and justify the uniform approach to utilisation and application of the provisions of the conventions on avoidance of double taxation which specify the regime of taxation of particular types of income and capital (property). Stemming from the factors giving rise to double (multiple) taxation, the author examines the mechanisms of elimination of double taxation contained therein and the legal technicalities employed to lay down such mechanisms in the tax treaties. Furthermore, the author elaborates on his vision regarding the possible commonly shared algorithm that could eliminate or minimise the errors in utilisation and application of the distributive rules of the double taxation treaties taking into account peculiarities of terminology and wording of the treaties as well as the systematic approach of treaty drafters to the formulation of distributive rules (rules establishing the specifics of the tax treatment of certain types of income and capital) contained therein.

APA, Harvard, Vancouver, ISO, and other styles

9

Bruk, Boris Ya. "Methodological Issues in the Use and Application of International Tax Treaties (Part 1)." Zakon 20, no. 11 (November 2023): 101–11. http://dx.doi.org/10.37239/0869-4400-2023-20-11-101-111.

Full text

Abstract:

In this article the author intends to develop and justify the uniform approach to utilisation and application of the provisions of the conventions on avoidance of double taxation which specify the regime of taxation of particular types of income and capital (property). Stemming from the factors giving rise to double (multiple) taxation, the author examines the mechanisms of elimination of double taxation contained therein and the legal technicalities employed to lay down such mechanisms in the tax treaties. Furthermore, the author elaborates on his vision regarding the possible commonly shared algorithm that could eliminate or minimise the errors in utilisation and application of the distributive rules of the double taxation treaties taking into account peculiarities of terminology and wording of the treaties as well as the systematic approach of treaty drafters to the formulation of distributive rules (rules establishing the specifics of the tax treatment of certain types of income and capital) contained therein.

APA, Harvard, Vancouver, ISO, and other styles

10

Karuna, Vikram. "International double taxation: Interpretation in the Indian context and general mitigation Measures." Journal of Management Research and Analysis 11, no. 1 (March 15, 2024): 41–45. http://dx.doi.org/10.18231/j.jmra.2024.008.

Full text

Abstract:

International Double Taxation poses a complex challenge with diverse interpretations, especially in the Indian context. This paper investigates the nuances of double taxation, focusing on legal principles, double taxation avoidance agreements (DTAAs), and their implications for residents and permanent establishments. It analyzes India's engagement in double taxation treaties, considering monistic and dualistic principles, legislative processes, and recent judicial developments. Case studies from French and Indian courts offer insights into treaty interpretation. The paper examines relief methods such as Exemption, Credit, Tax-sparing, and Expense Deduction, emphasizing their application within Indian tax treaties. Notably, Permanent Establishment (PE) significance in international taxation is explored through relevant case law. Conclusively, the paper underscores the importance of addressing international double taxation in the globalized era. It argues that while various relief methods exist, the Exemption method is most effective in mitigating double taxation, contrasting with the partial relief provided by the Credit method. The choice of relief method varies across nations based on financial considerations. This comprehensive exploration contributes to understanding international double taxation in the Indian context, highlighting legal interpretations, treaty dynamics, and mitigation measures. It advocates for harmonizing global approaches to achieve more effective and equitable solutions in international taxation.

APA, Harvard, Vancouver, ISO, and other styles

More sources

Dissertations / Theses on the topic "Double taxation Treaties"

1

Rijntjes, Dick. "Does Hong Kong need tax treaties?" Thesis, Click to view the E-thesis via HKUTO, 1996. http://sunzi.lib.hku.hk/HKUTO/record/B3862784X.

Full text

APA, Harvard, Vancouver, ISO, and other styles

2

Tadmore, Niv, and mikewood@deakin edu au. "The interaction between tax treaties and e-commerce re-examined." Deakin University. School of Law, 2003. http://tux.lib.deakin.edu.au./adt-VDU/public/adt-VDU20050719.085242.

Full text

APA, Harvard, Vancouver, ISO, and other styles

3

Dhoukar, Malek. "Treaty shopping : la fin d'un problème fiscal international?" Thesis, McGill University, 1999. http://digitool.Library.McGill.CA:80/R/?func=dbin-jump-full&object_id=31568.

Full text

Abstract:

Treaty Shopping can be defined as the "abuse" of tax conventions; it is a major international taxation topic. Its importance is increasing since the beginning of the 80's and the enactment of specific anti treaty shopping measures.
Those specific measures are the purpose of this thesis. Is treaty shopping a solved problem? Are those measures, taken principally by the undisputed leader of this policy, the United States, entirely efficient?
In order to answer those questions, a brief study of the phenomenon of treaty shopping is needed. The first part of this thesis deals with this issue.
The measures themselves are analyzed in the second part. Basically, we can classify them in two categories, the national and the limitation on benefits incorporated in tax conventions. Both of them present weaknesses and approximations. In those circumstances, it would be difficult to admit the end of treaty shopping. Moreover, those measures have raised new problems that must be addressed firstly in order to envisage an end to the practice of treaty shopping.

APA, Harvard, Vancouver, ISO, and other styles

4

Siegmann, Till. "The Impact of Bilateral Investment Treaties and Double Taxation Treaties on Foreign Direct Investments." St. Gallen, 2007. http://www.biblio.unisg.ch/org/biblio/edoc.nsf/wwwDisplayIdentifier/02218667001/$FILE/02218667001.pdf.

Full text

APA, Harvard, Vancouver, ISO, and other styles

5

Hjipanayi, Christiana. "Double taxation, tax treaties, treaty shopping and the European Community." Thesis, London School of Economics and Political Science (University of London), 2006. http://ethos.bl.uk/OrderDetails.do?uin=uk.bl.ethos.440460.

Full text

APA, Harvard, Vancouver, ISO, and other styles

6

Alalade, Olushola Adetayo. "Do double taxation treaties dictate between financial vertical integration and operational vertical integration? : case study on UK and USA, UK and Nigeria double taxation treaties." Thesis, University of Dundee, 2009. http://ethos.bl.uk/OrderDetails.do?uin=uk.bl.ethos.505610.

Full text

APA, Harvard, Vancouver, ISO, and other styles

7

Daniels, Paul. "The meaning of place of 'effective management' in the context of South African domestic tax law." Thesis, Nelson Mandela Metropolitan University, 2012. http://hdl.handle.net/10948/d1018822.

Full text

Abstract:

South Africa has a residence based system of taxation in which South African tax residents are taxed on their worldwide income. A company or other artificial person is regarded as a South African resident for tax purposes if it is incorporated, established or formed in South Africa or if its ‗effective management‘ is located in South Africa. Where a tax treaty determines in terms of its tie breaker rule that an artificial person is not resident in South Africa for treaty purposes, the company will also not be regarded as a tax resident in terms of South African domestic law. Treaties to which South Africa is party will often use the effective management‘ as the tie-breaker where a person other than an individual is resident in both Contracting states in terms of the respective states‘ domestic laws. The tests of ‗incorporation, established and formed‘ provide simplicity and certainty to governments but are easily open to manipulation by taxpayers. Therefore, the legislature found it necessary to incorporate effective management‘ as a test for residency into the Act. Effective management‘ is a substance over form concept which be described as a function which embodies the periodic, most senior executive management functions, which are required for the management of the affairs of the entity as whole. The test of effective management‘ by its very nature is concerned with where the crucial decisions are made in order to make a business function. To identify the location of effective management‘ it is necessary to enquire who calls the shots‘ in the context of the management of the company as opposed to who controls the company notwithstanding that there may in certain instances be overlap between the two functions. It is submitted that any person who, on the face of it seems unconnected to a company, could effectively manage‘ a company if that person is, in substance, responsible for the most senior executive management functions of the company. The discussion paper issued by SARS recognises the principal difficulties experienced with its current interpretation of the concept and makes valuable points, concessions and recommendations. It also recognised that the 'calling of shots' by the most senior executive is a critical marker of effective management‘ and that control of a company is irrelevant in determining effective management‘. To determine who effectively manages‘ a company each situation would have to be analysed on its own as it is not possible to create a definitive rule on the concept. In many cases the nature of the entity and its modus operandi would have to be taken into account to determine effective management.

APA, Harvard, Vancouver, ISO, and other styles

8

Felices-Gutiérrez, Vidal-Armando, and Vidal-Armando Felices-Gutiérrez. "El establecimiento permanente en los convenios para evitar la doble imposición bajo el modelo OCDE suscritos por Perú y el impacto de las iniciativas BEPS (Base Erosion and Profit Shifting) en el ordenamiento jurídico-tributario peruano." Master's thesis, Universidad de Lima, 2016. http://repositorio.ulima.edu.pe/handle/ulima/3109.

Full text

Abstract:

Trabajo de investigación que analiza el concepto de establecimiento permanente contenida en nuestra legislación y se irán identificando los problemas que surgen a la hora de aplicarlas; sumado a esto se analizaran los distintos convenios para evitar la doble tributación (CDI) suscritos por el Perú y por ultimo las iniciativas BEPS (Base Erosion and Profit Shifting), que son aplicables a los paises pertenecientes y adherentes de la OCDE.
Trabajo de investigación

APA, Harvard, Vancouver, ISO, and other styles

9

Cruceru, Luiza Brindusa. "Treaty shopping and the abuse of income tax conventions." Thesis, McGill University, 2005. http://digitool.Library.McGill.CA:80/R/?func=dbin-jump-full&object_id=83949.

Full text

Abstract:

This study proposes to analyze the phenomenon of tax treaty abuse and the use of tax treaties as tools to avoid or minimize the taxation by residents doing business in a foreign jurisdiction. This study analyses a particular strategy using tax treaties known as "treaty shopping." This paper will argue that treaty shopping constitutes an abuse of the tax treaty regime. However, this study rejects the traditional arguments against treaty shopping and proposes a different basis to challenge the legitimacy of this practice and to explain why this strategy constitutes an improper use of tax treaties.

APA, Harvard, Vancouver, ISO, and other styles

10

Moser, Karen. "Exit taxes in the context of double tax treaties: is the individual emigrating from South Africa protected against double taxation?" Master's thesis, Faculty of Commerce, 2019. http://hdl.handle.net/11427/30894.

Full text

Abstract:

For some countries, such as South Africa, a change of residence to another jurisdiction is a taxable event and may give rise to taxation of capital gains, based on a deemed disposal, even though there has not been an actual realisation of the capital gain. Such taxation is referred to as ‘exit or departure tax’ or ‘exit charge’. Double taxation of capital gains may arise when the former State of residence applies such an exit tax at the time when the taxpayer ceases to be a tax resident of that State, and when the new State of residence, thereafter, taxes the capital gain at the time of the actual disposal of the asset and realisation of the capital gain. A South African resident individual who emigrates, is therefore exposed to the risk of such double taxation. Double tax treaties following the OECD Model Convention aim at avoiding double taxation and provide distributive rules regarding capital gains in Article 13. This study examines if double tax treaties protect the individual emigrating from South Africa against the application of South Africa’s exit tax. Typical assets considered in the study are shares in a company, held as an investment. The analysis begins with an overview of the applicable rules of the South African Income Tax Act in respect of the capital gains tax levied when a South African resident individual emigrates and ceases to be a resident of South Africa. It then distinguishes between exit taxes in the strict sense (taxation of the accrued value at the time of emigration) and trailing taxes (extended tax jurisdiction, taxing the capital gains at the time of realisation after the emigration). The analysis then concentrates on four subquestions, i.e. (i) whether Art. 13(5) of the OECD Model Convention (2017) applies to exit taxes, (ii) whether Art. 13(5) of the OECD Model precludes the application of an exit tax, (iii) to what extent double tax treaties are able to mitigate the risk of double taxation in the case of exit taxes, and (iv) whether the tax treaty network of South Africa provides any protection against double taxation caused by the application of the South African exit tax. It was concluded that it is generally accepted, with the exception of a minority of authors, that the distributive rule of Art. 13(5) OECD Model includes capital gains arising from a deemed alienation and that that article does not preclude the former State of residence from applying its exit tax at the time when the person is still a resident of that State. However, Art. 13(5) OECD Model does preclude the application of trailing taxes after the person ceases to be a resident. In order to allow the application of trailing taxes, double tax treaties need to explicitly provide for this in a specific clause in the capital gains-article of the tax treaty. The exclusive allocation of taxing rights in art. 13(5) OECD Model in favour of the State of residence does not mitigate the risk of double taxation in the case of exit taxes in the strict sense. In order to avoid double taxation of that portion of the capital gain that already has been subjected to an exit tax in the strict sense, double tax treaties need to include a specific clause in the capital gains-article of the tax treaty, which obliges the new State of residence, when taxing the capital gain at the moment of realisation, to take into account the value that was subjected to the exit tax (step-up in the base cost). South Africa concluded only two treaties which provide for such a step-up in the base cost, one of which has not yet entered into force. This leaves the individual South African resident who emigrates, largely unprotected against double taxation of capital gains at a tax treaty level. It is recommended that South Africa include such specific clauses that provide for a step-up in the base cost in more tax treaties, especially in tax treaties with countries that do not already grant a step-up in terms of their domestic tax laws.

APA, Harvard, Vancouver, ISO, and other styles

More sources

Books on the topic "Double taxation Treaties"

1

Haccius, Charles. Double taxation agreements. Dublin: Institute of Taxation in Ireland, 1998.

Find full text

APA, Harvard, Vancouver, ISO, and other styles

2

States, United. Tax treaties. 2nd ed. Chicago, IL (4025 W. Peterson Ave., Chicago 60646-6085): CCH Inc., 2004.

Find full text

APA, Harvard, Vancouver, ISO, and other styles

3

Organisation for Economic Co-operation and Development., ed. 1963 and 1977 OECD model income tax treaties and commentaries: A comparative presentation. Deventer [Netherlands]: Kluwer Law and Taxation, 1987.

Find full text

APA, Harvard, Vancouver, ISO, and other styles

4

K, Srinivasan. Guide to double taxation avoidance agreements. Edited by Bhargava B. P. New Delhi: Vidhi Foundation, 1992.

Find full text

APA, Harvard, Vancouver, ISO, and other styles

5

Newns, Ralph. Double taxation relief for shipping. London: Lloyd's of London Press, 1988.

Find full text

APA, Harvard, Vancouver, ISO, and other styles

6

Walsh, Mary. Irish tax treaties. Dublin: Butterworths, 2003.

Find full text

APA, Harvard, Vancouver, ISO, and other styles

7

Congress, International Fiscal Association. Double taxation treaties between industrialised and developing countries: OECD and UN models, a comparison : proceedings of a seminar held in Stockholm in 1990 during the 44th Congress of the International Fiscal Association. Deventer: Kluwer Law and Taxation Publishers, 1992.

Find full text

APA, Harvard, Vancouver, ISO, and other styles

8

US GOVERNMENT. US tax treaties. Deventer: Kluwer Law and Taxation Publishers, 1991.

Find full text

APA, Harvard, Vancouver, ISO, and other styles

9

Mittal, D. P. Taxmann's Indian double taxation agreements & tax laws. 5th ed. New Delhi: Taxmann Allied Services, 2007.

Find full text

APA, Harvard, Vancouver, ISO, and other styles

10

Ireland. Agreement between Ireland and the Republic of Finland for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and capital gains: Done at Dublin on 27 March, 1992 : presented to both houses of the Oireachtas by the Minister for Foreign Affairs. Dublin: Stationery Office, 1992.

Find full text

APA, Harvard, Vancouver, ISO, and other styles

More sources

Book chapters on the topic "Double taxation Treaties"

1

Heintzen, Markus. "Chapter D.10: Double taxation treaties." In Encyclopedia of Private International Law, 566–74. Edward Elgar Publishing, 2017. http://dx.doi.org/10.4337/9781782547235.d.10.

Full text

APA, Harvard, Vancouver, ISO, and other styles

2

"Double-taxation treaties concluded by Tunisia." In OECD Investment Policy Reviews, 192–93. OECD, 2012. http://dx.doi.org/10.1787/9789264179172-13-en.

Full text

APA, Harvard, Vancouver, ISO, and other styles

3

Bizioli, Gianluigi. "Qualification Conflicts and Tax Treaties." In The Oxford Handbook of International Tax Law, 285—C17N28. Oxford University Press, 2023. http://dx.doi.org/10.1093/oxfordhb/9780192897688.013.18.

Full text

Abstract:

Abstract This chapter examines qualification conflicts and tax treaties. Qualification conflicts in tax treaty law raise two different issues. The first involves defining the boundaries of the topic and, in particular, the differences and the overlapping of the contiguous terms and activities of interpretation, classification, and characterization. This issue is common to every legal order and the conflicts are always due to a varying interpretation by two jurisdictions. The second, differently, involves the consequences of these conflicts on international taxation, in particular double taxation or double non-taxation of the same income in the hands of the same taxpayer by two (or more) different jurisdictions. The chapter presents a literature review of the issue, with particular emphasis on the OECD and the UN documents, on the commentaries, and on monographs on the topic. It looks at the critical analysis of the causes as well as the solutions provided, their coherence with the principles of international taxation, and ability to pursue the objectives.

APA, Harvard, Vancouver, ISO, and other styles

4

Hearson, Martin. "Tax Treaties." In Global Wealth Chains, 49–67. Oxford University Press, 2022. http://dx.doi.org/10.1093/oso/9780198832379.003.0003.

Full text

Abstract:

In this chapter, Martin Hearson explains why taxation treaties should be understood as assets that coordinate activity within global wealth chains. Hearson describes how multinational enterprises have changed their use of tax treaties. At first it was to remove the threat of double taxation, while in the contemporary period it is to facilitate advanced tax planning and ease internal transactions within multinational enterprises. Hearson describes how global professional service firms, especially the Big Four global accounting firms, are involved in establishing tax treaties, and how value chain activity is being restructured around wealth chain articulation. This chapter shows how legal forms can be understood as captive and hierarchy forms of wealth chain management, as well as how regulatory interventions to constrain such tax planning are important but not especially effective.

APA, Harvard, Vancouver, ISO, and other styles

5

Hemels, Sigrid. "Charities in Tax Conventions." In The Oxford Handbook of International Tax Law, 335—C20N44. Oxford University Press, 2023. http://dx.doi.org/10.1093/oxfordhb/9780192897688.013.21.

Full text

Abstract:

Abstract This chapter focuses on tax incentives for charities. The OECD observed in its 2020 tax policy study Taxation and Philanthropy that most countries provide tax incentives for philanthropic giving and philanthropic entities. Charities cross borders in various ways including through international initiatives, investments, and fundraising. This may result in double taxation, both by the resident state of the charity and by the source state of the income. Many countries have concluded bilateral treaties to avoid double taxation (double taxation conventions (DTCs)) to solve or mitigate situations of double-income taxation. Model conventions (MCs) usually serve as the starting point for negotiations. The chapter first analyses the reason why many countries restrict tax incentives to resident charities as this is often the cause of double or single taxation where the purpose of a tax incentive is no taxation. It then assesses whether charities have access to DTCs and, if so, whether they have a special position.

APA, Harvard, Vancouver, ISO, and other styles

6

Peter, Hongler. "2 Sources of the International Law of Taxation." In International Law of Taxation. Oxford University Press, 2021. http://dx.doi.org/10.1093/law/9780192898715.003.0002.

Full text

Abstract:

Chapter 2 is the main part of the book and it is structured along the different sources of the international law of taxation. This includes (i) treaties, (ii) customary international law, (iii) general principles of international law, and (iv) soft law. The chapter contains a comprehensive outline of the functioning of double tax treaties and other treaties focusing on tax matters such as treaties on mutual exchange of taxpayer information. The entire OECD MC is discussed and reference is made to brief case studies in order to allow the reader a better understanding of the international tax regime. A particular focus is in on the functioning the allocation rules in Arts 6–22 OECD model convention, however, this chapter also includes general remarks on the interpretation of tax treaties and soft law used in international tax matters. The chapter closes with a concise overview of the EU tax system.

APA, Harvard, Vancouver, ISO, and other styles

7

Altenburg, Nadia, and Dietmar Gosch. "Beneficial Ownership and Tax Treaties." In The Oxford Handbook of International Tax Law, 373—C22N94. Oxford University Press, 2023. http://dx.doi.org/10.1093/oxfordhb/9780192897688.013.23.

Full text

Abstract:

Abstract This chapter addresses the principle of beneficial ownership and tax treaties. The principle of beneficial ownership has to be placed in context with the introduction of modern income tax systems, the subsequent occurrence of double taxation, as well as efforts to ensure that the consequently introduced double taxation treaties are correctly applied and grant benefits only to the actual economically entitled taxpayer. The scope of the beneficial ownership principle therefore extended the idea of preventing non-entitled parties from obtaining treaty protection. The term ‘beneficial owner’ was introduced for the first time into articles 10(2), 11(2), and 12(1) of the final version of the 1977 OECD Model, as well as into the respective passages of the Commentary on the OECD Model Convention. However, the introduction of the term into the 1977 OECD Model cannot be understood as a remarkable change when it comes to treaty application and interpretation. The explicit introduction of the beneficial ownership principle can be marked as the starting point of the discussion of whether the term is to be understood in a narrow ‘legal’ sense or based on a broad understanding, building on economic principles.

APA, Harvard, Vancouver, ISO, and other styles

8

Ecker, Thomas. "Tax Treaties – A Solution to VAT/GST Double Taxation." In Value Added Tax and Direct Taxation: Similarities and Differences. IBFD, 2009. http://dx.doi.org/10.59403/2d9em2y050.

Full text

APA, Harvard, Vancouver, ISO, and other styles

9

Marethová, Zuzana, and Michal Liška. "Interpretation of Treaties for the Avoidance of Double Taxation with Practical Examples." In European Financial Law in Times of Crisis of the European Union, 365–76. Ludovika Egyetemi Kiadó, 2019. http://dx.doi.org/10.36250/00749.35.

Full text

Abstract:

This contribution deals with the problem of interpretation of treaties for the avoidance of double taxation from the point of interpretative models theory. The main aim of the contribution is to confirm or disprove the hypothesis that the continental interpretative canon or Anglo–Saxon one should be used during the procedure of interpretation of the legal concept of treaties.

APA, Harvard, Vancouver, ISO, and other styles

10

Barthel, Fabian, Matthias Busse, Richard Krever, and Eric Neumayer. "The Relationship between Double Taxation Treaties and Foreign Direct Investment." In Tax Treaties: Building Bridges between Law and Economics. IBFD, 2010. http://dx.doi.org/10.59403/34p3q6q001.

Full text

APA, Harvard, Vancouver, ISO, and other styles

Conference papers on the topic "Double taxation Treaties"

1

Armeanic, Alexandru. "Scope Of International Treaties To Avoid Double Taxation." In 27th International Scientific Conference “Competitiveness and Innovation in the Knowledge Economy”. Academy of Economic Studies of Moldova, 2024. http://dx.doi.org/10.53486/cike2023.61.

Full text

Abstract:

The conventions concluded by the Republic of Moldova on the notion of "person" do not include the element of society, replacing it with the notion of a legal entity. Data: However, the conventions concluded by the Republic of Moldova in the article that will refer to the general definitions (art. 3), will not even refer to the content of a legal person, as is done in the case of the Model Convention, when it refers to the notion of "society". Methodology: These distinctions do not have deviant interpretations, because the notion of "company" is defined by the Model Convention in the following way: "the term "company" designates any legal person or any entity that is considered for taxation purposes as a legal person". Findings: Therefore, in the broad sense of the concept of "legal person", used in the conventions concluded by the Republic of Moldova, only those legal persons that are taken into account "for the purpose of taxation" can be defined, i.e. legal persons that are subject to taxation with regard to taxes which are covered by the convention. In the case of legal entities, when it is a resident of both contracting states, it is considered resident in that contracting state where the effective management body is located. It is necessary to underline the fact that the international benefits of elimination of double taxation are offered only to subjects resident in one or both signatory states. A taxable subject who is not resident in one of these states will not be able to benefit from the provisions of the conventions.

APA, Harvard, Vancouver, ISO, and other styles

2

Dulevski, Stoycho. "SOME ASPECTS REGARDING THE TIME CRITERION IN THE OECD-MC." In THE LAW AND THE BUSINESS IN THE CONTEMPORARY SOCIETY 2020. University publishing house "Science and Economics", University of Economics - Varna, 2020. http://dx.doi.org/10.36997/lbcs2020.241.

Full text

Abstract:

The Double Tax Treaties (DTTs) are an important regulator in international taxation. Their provisions outline the prerequisites, which implementation determines their proper application. It is noteworthy that time criterion is derived in some of them. This necessitates their examination both from theoretical and practical perspective.

APA, Harvard, Vancouver, ISO, and other styles

Reports on the topic "Double taxation Treaties"

1

Kinda, Harouna, and Abrams M. E. Tagem. Double taxation treaties and resource revenue mobilization in developing countries: A neural network approach. UNU-WIDER, October 2023. http://dx.doi.org/10.35188/unu-wider/2023/433-5.

Full text

APA, Harvard, Vancouver, ISO, and other styles

2

Trachtenberg, Danielle. Tax Barriers to Services Imports in Latin America and the Caribbean: The Case of IT Services. Inter-American Development Bank, October 2022. http://dx.doi.org/10.18235/0004511.

Full text

Abstract:

This document uses responses from a questionnaire to examine whether tax policy is a barrier to information technology (IT) services imports in Latin America and the Caribbean. The responses show that existing policies do not create a level playing field in the upfront tax burdens paid on transactions, although whether domestic or imported IT services face lower burdens varies by country. The responses also underline that the issue of taxation of services is primarily taken up in double taxation treaties rather than preferential trade agreements, suggesting that trade agreements do not ensure equitable treatment between domestic and imported services as effectively for services as for goods.

APA, Harvard, Vancouver, ISO, and other styles

3

Shehaj, Pranvera, and Martin Zagler. Asymmetric Double Tax Treaties and FDI in Developing Countries: The Role of the Relief Method and Tax Sparing. Institute of Development Studies, March 2023. http://dx.doi.org/10.19088/ictd.2023.009.

Full text

Abstract:

This study focuses on asymmetric tax treaties and investigates the impact of OECD member states’ double tax relief method and of treaty tax sparing provisions on investments in developing countries, while considering network effects. In addition, it analyses the impact of a residence country’s tax relief method on the source country’s tax policy. Our results suggest that having a treaty between the OECD member state and the developing country, which improves the investor’s conditions in terms of tax burden by changing the unilateral tax relief method, increases FDI to the developing country. The positive effect prevails when investigated within investments made through the direct route from home to host. Furthermore, results suggest that OECD member states offer tax sparing provisions mostly to less-developed economies, which already receive very low, if any, foreign direct investment. Finally, we find that developing countries set higher corporate income tax (CIT) when the OECD member state relieves double taxation through the exemption method, as compared to when it offers a foreign tax credit, while the inclusion of tax sparing agreements has a positive effect on the CIT.

APA, Harvard, Vancouver, ISO, and other styles

We offer discounts on all premium plans for authors whose works are included in thematic literature selections. Contact us to get a unique promo code!